Supreme Court of Georgia
Bates v. State
December 14, 2021313 Ga. 57
Summary
The court affirmed the convictions and sentences, holding that the defendant failed to establish either deficient performance or prejudice under the governing ineffective-assistance standard. Counsel's decisions concerning PTSD-related defenses, pretrial notice, subpoenaing a federal witness, and challenging the State's expert were either reasonable strategic choices or, assuming deficiency, did not affect the outcome. The court also held that any cumulative prejudice was insufficient to warrant a new trial.